Estate of Meyer v. Commissioner
United States Tax Court
Following an initial audit of the Federal estate tax return of Ella T. Meyer, petitioner received a document from the district director of internal revenue entitled "Estate Tax Closing Letter" which showed that a net estate tax of $ 68,883.78 had been paid and stated that the letter could be exhibited as evidence that the Federal estate tax liability of the estate had been discharged.
Read the full summary
Following an initial audit of the Federal estate tax return of Ella T. Meyer, petitioner received a document from the district director of internal revenue entitled "Estate Tax Closing Letter" which showed that a net estate tax of $ 68,883.78 had been paid and stated that the letter could be exhibited as evidence that the Federal estate tax liability of the estate had been discharged. Held: The letter did not constitute a final closing agreement under sec. 7121, I.R.C. 1954. It also does not estop the Commissioner from making a timely determination of a deficiency in estate tax based upon an…
1Opinion of the Court
opinion
Dawson, Judge:
On November 18, 1971, petitioner filed a “Motion for Severance of Issues” and a “Motion to Dismiss, or in the Alternative, to Strike Answer.” On January 10,1972, petitioner filed a memorandum in support of its motions, and on February 15,1972, respondent filed a memorandum brief in reply. The Court set the motions for hearing in Milwaukee on March 13, 1972. Without objection by respondent, the motion for severance of issues was granted, and the parties submitted a full stipulation of pertinent facts with respect thereto. All of the stipulated facts are found accordingly.
At…
2Cases cited28 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
- Schuster v. CommissionerUnited States Tax Court · 1959
- Burnet v. PorterSupreme Court of the United States · 1931
23 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Hudock v. CommissionerUnited States Tax Court · 1975
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
- Montgomery v. CommissionerUnited States Tax Court · 1975
- Schwager v. CommissionerUnited States Tax Court · 1975
- Estate of Sivyer v. CommissionerUnited States Tax Court · 1975
33 more not listed; retrieve them via the Exa API.